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1. New Jersey Tax Amnesty Program Commences Shortly
April 21, 2009
If you have any questions regarding procedural aspects of the amnesty program, or special situations such as...
3. New Jersey Legislation Repeals Regular Place of Business and Throwout Provisions
December 28, 2008
Based on the new legislation, taxpayers will have the right to...
5. First Decision Regarding Application of Intangible Expense Add-Back Statute Affirmed
October 6, 2008
The issue was whether the Department could require the taxpayer to include in taxable income...
7. New York State Tax Shelter Voluntary Compliance Initiative
September 12, 2008
Pursuant to the initiative, the Department of Taxation and Finance may waive...
9. Reminder: Nevada Tax Amnesty Program is Underway
August 7, 2008
In order to qualify for the program...
11. Massachusetts Legislation Update
July 11, 2008
Massachusetts recently passed significant legislation that...
13. NYS TSB-M on Treatment of Sale of Subsidiary Included in Combined Report
March 15, 2008
TSB-M-08(3)C sets forth the Department’s policy on how to treat the gain or loss on the sale of stock of a subsidiary included in a combined report in light of...
15. Reversal of First Decision Concerning Application of Intangible Expense Add-Back Statute
February 26, 2008
The relevant provisions of the Alabama statute required a corporation, when computing its taxable income, to...
17. Decision Regarding Application of Intangible Expense Add-Back Statute in Ohio
January 30, 2008
A recent decision in Ohio illustrates the difficulty taxpayers face in...
19. Economic/Affiliate Nexus
August 25, 2007
Under these theories, a corporation with no physical presence in a taxing state can...
21. New York Developments: Intercompany Transactions and Forced Combination
June 10, 2007
New York City has not conformed to the recent State amendment, potentially allowing for...
23. MTC Voluntary Compliance Program – Tax Shelters
May 31, 2007
Taxpayers are forewarned that once the program ends, the states intend to...
25. New Jersey Audit Initiative Regarding Intercompany Transactions
May 14, 2007
In the current environment, taxpayers should develop and implement appropriate measures to...
27. New York State Regulations on Taxation of Corporate Partners
February 23, 2007
Two methods, the aggregate method and the entity method, are provided for corporate partners to...
29. First Decision Concerning Application of Intangible Expense Add-Back Statute
February 2, 2007
A case of first impression has been decided regarding...
31. Lanco Decision Affirmed by New Jersey Supreme Court
October 15, 2006
Based on Lanco, the corporation business tax may be imposed on a corporation with...
33. Recent New Jersey Legislation
August 24, 2006
Highlights of the legislation include...
35. Planning to Minimize Expense Disallowance Adjustments
August 14, 2006
An increasing number of states have addressed intercompany pricing issues by...
37. Texas Overhauls Franchise Tax
June 18, 2006
The current franchise tax is being replaced by...
39. Proposed Regulation Regarding Statutory Disallowance Provisions in Massachusetts
May 18, 2006
The proposed regulation is intended to...
41. Settlement Opportunities May Exist in New Jersey in Light of Lanco Litigation
April 26, 2006
Taxpayers entering into settlements with New Jersey would be permitted to...
43. Recent Decision in Pennsylvania May Provide Planning Opportunities
February 13, 2006
The holding may provide planning opportunities for taxpayers that would benefit from...
45. Proposed New York State Tax Law Changes
January 13, 2006
The Budget contains proposed tax law changes intended to...
47. Reminder: New York State and City Voluntary Disclosure Programs Are Underway For Taxpayers Involved In Tax Shelters January 3, 2006.
Voluntary disclosure programs with respect to tax avoidance transactions (i.e., tax shelters) are becoming prevalent...
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2. Connecticut Tax Amnesty
March 21, 2009
Amnesty is available to any taxpayer...
4. Deadline Extended for Maryland Corporate Income Tax Information Reporting
October 23, 2008
Failure to comply with the information reporting requirements may result in...
6. Deadline is Approaching for Maryland Corporate Income Tax Information Reporting
September 21, 2008
By way of background, Maryland recently passed legislation requiring the reporting of...
8. Matter of the Summons Issued to Ernst & Young, LLP
August 29, 2008
The case is illustrative of the danger taxpayers face with respect to the potential disclosure on audit of...
10. FIN 48 and State and Local Taxes
July 31, 2008
FIN 48 disclosures and workpaper details may serve as a roadmap for...
12. New Jersey Throwout Rule Survives Facial Constitutionality Challenge
June 19, 2008
The plaintiff argued that the throwout rule, in effect, enables New Jersey to...
14. New TSB-M on NYS Combined Reporting
March 14, 2008
By way of background, for tax years beginning after 2006, New York State amended the Tax Law with respect to...
16. Reminder: Illinois Corporate Business Tax Amnesty Program is Underway
February 10, 2008
Under the amnesty program, the Illinois Secretary of State is authorized to...
18. Reversal in New York Treatment of Sale of Subsidiary Included in Combined Report
December 22, 2007
The filing of returns on a combined basis in New York presents many issues related to...
20. New York State Memorandum on Listed Transaction
July 5, 2007
A taxpayer that has participated in a reportable transaction during its taxable year is required to...
22. New York State Amends Combined Reporting Requirements
June 4, 2007
Based on the amendments, combination is permitted or required where...
24. Texas Tax Amnesty
May 21, 2007
Taxpayers with significant tax exposure in Texas should strongly consider...
26. FIN 48 and Voluntary Disclosure
March 24, 2007
One solution to alleviate a significant FIN 48 nexus reserve is...
28. New York State Regulations Defining and Providing Disclosure Requirements for Reportable Transactions
February 14, 2007
A taxpayer that has participated in a reportable transaction during its taxable year is required to...
30. California Franchise Tax Board Notice 2006-3
October 15, 2006
California continues to scrutinize how taxpayers report...
32. Florida Intangible Tax Repealed
August 30, 2006
The Florida Department of Revenue will continue to...
34. Microsoft Corp. v. Franchise Tax Board; General Motors Corp. v. Franchise Tax Board
August 20, 2006
The California Supreme Court has just decided a pair of cases involving the controversial issue of whether...
36. Matter of Bausch & Lomb, Inc. and Affiliates
July 25, 2006
There have been many other determinations that have hinged on whether...
38. New York State Revises Position on Convenience of the Employer Test
May 29, 2006
By way of background, the convenience of the employer test is used in determining...
40. Toys “R” Us, Inc. v. Franchise Tax Board
May 4, 2006
The issue of whether gross or net proceeds from securities/investment transactions are includible in the receipts factor for apportionment purposes continues to...
42. The Importance of Business Purpose and Economic Substance
April 8, 2006
The concepts of business purpose and economic substance are generally utilized by states to...
44. Recent Economic/Affiliate Nexus Decisions
January 20, 2006
In recent years, the states have aggressively expanded the principle of nexus to include...
46. Reminder: Ohio Tax Amnesty Program is Underway
January 7, 2006
Under the amnesty program, the Ohio Department of Taxation is authorized to...
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